MORGAN, LEWIS & BOCKIUS LLP
ONE FEDERAL STREET
BOSTON, MASSACHUSETTS 02110
January 25, 2017
VIA EDGAR
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Re: Pioneer Series Trust X (File Nos. 333-89354; 811-21108)
Registration Statement on Form N-1A
Ladies and Gentlemen:
This letter is to respond to comments we received from Mr. Jay Williamson of
the Staff of the Division of Investment Management of the Securities and
Exchange Commission (the "Commission") regarding Post-Effective Amendment
No. 41 to the Registration Statement on Form N-1A of Pioneer Series Trust X
(the "Registrant"), with respect to Class T shares of Pioneer Fundamental
Growth Fund (the "Fund"). Following are the Staff's comments and the
Registrant's responses thereto:
1. Comment: The Staff requested that the line item "Net Expenses" in the
Fee Table be revised to read "Total Annual Fund Operating
Expenses After Fee Waiver and Expense Reimbursement."
Response: The Registrant will revise the line item "Net Expenses" in the
Fee Table to read "Total Annual Fund Operating Expenses After
Fee Waiver and Expense Reimbursement."
2. Comment: The Staff noted that, based on publicly available information,
the Fund appears to have significant allocations to the
information technology and consumer discretionary sectors. The
Staff requested that the Registrant add appropriate sector risk
disclosures if these sector exposures are expected to persist
over time.
Response: The Registrant notes that the disclosure in the "More on the
Risks of Investing in the Fund," section of the Prospectus
includes disclosure regarding the information technology and
consumer discretionary sectors. The Registrant will revise the
"Market Segment Risk" disclosure in the "Principal Risks"
section of the Prospectus to address exposure to the
information technology and consumer discretionary sectors. As
revised, the disclosure in the "Principal Risks" section of the
Prospectus will state:
MARKET SEGMENT RISK. To the extent the fund emphasizes, from
time to time, investments in a market segment, the fund will be
subject to a greater degree to the risks particular to that
segment, and may experience greater market fluctuation, than a
fund without the same focus.
Industries in the technology segment, such as information
technology, communications equipment, computer hardware and
software, and office and scientific equipment, are generally
subject to risks of rapidly evolving technology, short product
lives, rates of corporate expenditures, falling prices and
profits, competition from new market entrants, and general
economic conditions.
Industries in the consumer discretionary segment, such as
consumer durables, hotels, restaurants, media, retailing and
automobiles, may be significantly affected by the performance
of the overall economy, interest rates, competition, consumer
confidence and spending, and changes in demographics and
consumer tastes.
3. Comment: The Staff noted that the Registrant includes extensive
disclosure regarding the risks of investing in real estate
securities and REITs in the "More on the Risks of Investing in
the Fund" section of the Prospectus, however, the principal
investment strategy disclosure does not address these types of
investments to the same extent. The Staff requested that the
Registrant consider re-locating the risk disclosure included in
the "More on the Risks of Investing in the Fund" section of the
Prospectus or revising the principal investment strategy
disclosure to address the Fund's investment in real estate
securities and REITs.
Response: The Registrant will re-locate the disclosure regarding the
risks of investing in real estate securities and REITs in the
"More on the Risks of Investing in the Fund" section of the
Prospectus to the Statement of Additional Information.
4. Comment: The Staff requested that the Registrant update the disclosure
under "Investment Adviser" relating to UniCredit S.p.A. as
necessary.
Response: The Registrant will update the disclosure referenced by the
Staff to reflect that UniCredit S.p.A. has announced that it
has entered into a binding agreement for the sale of its
Pioneer Investments business, which includes the Fund's
investment adviser, to Amundi S.A.
5. Comment: The Staff requested that the Registrant confirm whether there
will be any scheduled variations in or eliminations of sales
loads for Class T shares and, if so, provide appropriate
disclosure regarding such scheduled variations in or
eliminations of sales loads. The Staff referred the Registrant
to the 2016 IM Guidance Update regarding mutual fund fee
structures.
Response: The Registrant confirms that the scheduled variations in sales
loads for Class T shares are set forth on pages 38-39 of the
Prospectus.
6. Comment: The Staff asked if there are any limitations on eligibility for
Class T shares and, if so, to revise the "Share
Class Eligibility" section accordingly.
Response: The Registrant will add disclosure under "Share
Class Eligibility" to clarify that Class T shares are available
only through a financial intermediary.
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Please call the undersigned at (617) 951-8458 or Toby Serkin at (617)
951-8760 with any questions.
Sincerely,
/s/ Jeremy Kantrowitz
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Jeremy Kantrowitz
cc: Terrence J. Cullen
Christopher J. Kelley
Roger P. Joseph
Toby R. Serkin
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